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I November 9, 1976 -
C . Richard Procense
District Engineer
O Colorado Division of Highways .
P.O. Box 2107 '.~
AT Grand Junction, Colorado 81501
~e~i Dear Dick:
i We have had an opportunity to review the Draft Emrironmental Impact
Statement for "Carbondale East" and have a number of observations.
First, we would like to express our appreciation for the cooperation
• and consideration extended to our County by the Division and your
• office, specifically. We believe the Halprin work did provide a
benefit and represents a sensitive analysis of opportunities available
- •to us with regard to the highway.- We have received the Halprin report
as a useful work, but everyone must understand that one report could
not possibly identify all of the impacts created by the construction
of a 40 to 65 million dollar highway in our area.
- Following this critique of the Carbondale East D.E.I.S. is a proposal
• for the development of a joint transportation program between the
.- State Highway Department and local governments within the Roaring
Fork Valley. If instituted, this program could provide immediate
-relief to some of the current transportation problems of this valley.
Repeated reference is made is the D.E.I.S. to Pitkin County's fear
of the growth implications of a four ,lane improvement .• Our resistence
is characterized as based in a concern for the new tourist and permanent
home development that would follow the construction of a new highway.
-While it is a legitimate fear, we realize that we control our own'
destiny with respect to land use activities. .Our concerns go beyond
simple land use matters and involve further quesitons as to the long
term role of the automobile in Aspen and Pitkin County as the primary
means of movement for the local resident and tourist alike. We. note,
however, that beyond the :county Tine at Basalt we have no jurisdiction
and the .four lane will make commuting from the Basalt-Carbondale
area where land is cheaper and winters less severe and this~wil], create
more traffic on this highway and this impact should be analyzed.
The criticisms of the D.E.I.S. fall into four categories and are grouped
within those areas as follows:
~D T~ e-n1 yV-1q-1~_ rtD s t ~nJ 5~-a-remen~-r ~s K e~5'o { u-n.e•~~
..... _.
Richard Procense
November 9, 1976
Page Two
General Comments
1. Alternative 1-G is in direct contradiction to the Federal Aviation
Administration's funded and approved masterplan for the Aspen/
Pitkin County (Sardy Field) Airport. This master plan had assumed
that highway expansion would occur to the east of the existing
alignment. Pitkin County has just received approval of nearly
$Z.5 million of federal funds to acquire properties consistent
with the approved master plan. Strong continued consideration of
alternative alignment 1-G would endanger the continuance of the
federal governments support of the County's approved airport
master plan.
2. Qne principal engineering disadvantage of Alternative 2-D mentioned
on page 66 is that long stretches of S.H. 82 would be abandoned
to other uses which could become a maintenance liability of the
County. It is unlikely that the County would assume responsi-
bility for such a liability and, in all likelihood~~would probably
insist on removal and complete restoration of any abandoned sections
of S.H. 82. ~ .
,,:
3. -There was no development of an implementation schedule or phasing
plan for any of the considered alternatives. The D.E.I.S.
recognizes the possibility of a twenty-five year construction
period and stresses the current unsafe condition of the highway.
An analysis of the most dangerous sections of the entire project
length should be made, with an accommodating phasing plan indicating
the relative order. and cost of each phase of each alternative.
It is likely that this process may provide for the construction
of an improved two lane facility as the first phase of an eventual
four lane improvement.
• 4. The D.E.Z.S., in discussing Alternate 3 (Improved two lane from
Sardy to Aspen) states on page 72 that "This alternate would not
• ~ be eligible for federal participation because capacity and safety
criteria presently far exceed two lane standards." This statement
points out that the consideration of using other than federal
funds was foregone. If the existing two lanes were upgraded
immediately by the State a significant increase in safety would be
experienced. Currently the highway is a State responsibility and
the continuing process of study, analysis and generation of federal
funds takes indefinite lengths of time-which by default allow for
" the continuance of the unsafe conditions of S.H. 82. This D.E.I.S.
should consider the possibility of the State expending its own
maintenance funds to immediately improve this critical section of
S.H. $2 (Sardy to Aspen) rather than allow the continuance of the
existing situation. A $3.3 million improvement is not beyond the
financial capabilities of the State Highway Department.
'~ _ ..
Page~Three
5. Page $2 of tl:e D.E.I.S. addresses the issue of the "Effect of
Auto Restraint Policies." Ttie County is currently underway with
a thorough examination of all possible ways to reduce the impact
of the automobile with respect to various alternative line haul
modes being considered for the Aspen/Snowmass corridor. These
automobile restriction plans should be included in the final
Carbondale East E.I.S. as County adoption of an autcmobile re-
striction plan could work in contradiction to any of the highway
alternatives.
6. The best of the four lane alternatives offer the stated benefit of
- providing an hourly capacity of 4,000 cars/hour or a service level
"C" for the estimated 1990 average sumcner peak hourly volume.
It is our observation that without substantial circulation and
parking improvements in the City of Aspen, there will be no
place for these cars to go. Like any phys~~.cal system, improved
Capacities of any kind will result in increased pressures elses.There
with the resultant breakdown of a newly created "weak-link." Two ,
- principal characteristics of the City of Aspen militate against
the development of the scale of automobile movement envisioned
by 'a four lane entrance higFiway. First, the nineteenth century
- - .urban design pattern inherited from the City's early surveyors
did not include attractive provisions for the automobile. Sub-
• stantially increased parking could be integrated into the existing
urban fabric of Aspen only at a great cost. The concept of above
grade parking structures has been consistently rejected by the
Community as undesirable. Aspen derives it's historic character
and tourist appeal from the restored Victorian environment. It
is hard to conceive of an above grade parking structure that could
' ~~ompliment the existing setting. A parking study done for the City
• in 1975 by Pizzagali revealed the potential for a 3-tiered parkin;.,
- structure under Wagner Park to handle some 500 cars. A brief
survey of national building experiences :,y our planning staff
indicates an average construction cost of $3,000.00 per space of
below grade parking. To build space for 600 cars (an equivalent
of 12 blocks of angle parking) would cost the Aspen community
' - $4.8 million for construction plus $4.8 million financing costs for
-..a total parking cost of $9.6 million dollars of which none could
be financed by any other governmental agency.
Limited revenues could be drawn from parking-users due to the
seasonal fluctuation in tourism. Inevitably local property and
sales taxes would be called upon to retire debts for such structures.
- Secondly, there is a serious question as to the desirability of
accommodating 4000/cars hour in terms of maintenance of a quality
., _zesort experience. The volumes envisioned in the D.E.I.S. are remini-
scent of the traffic in urban areas-which vacationers seek to
escape by coming to Aspen.
,~~-
November 9, 1916
Page Four
It is our conclusion then that Aspen is typical of communities
developed prior .to the inc,~ption of the~autotnobile. The great
eastern cities stand as testimony to the folly of connecting urban
infrastructures with highways that provide greater capacity than
cities are physically able to absorb.
The direct costs to Local government for parking and circulation
improvements created by a four lane are not identified in the
D.E.I.S. and should be. '
7. We believe that a four lane improvement w-i11 substantially affect.
the Lourist mode of arrival from the gateway cities of Denver and
Grand Junction to Aspen-. This is of equal direct concern to us
with the increase in residential development that Till follow a
. .. ~ new highway. The D.E.I.S. forecasts a 6l annual increase in highway
use to 1990. With the four lane improvements discussed, we have no
doubt that this will become a self-fulfilling prophecy. Auto arrival
_ by tourists is a serious concern to the community and serious
- actions are being discussed in our UMTA "Alternatives Analysis"
• to provide alternative modes of arrival. These.inelude concerted
efforts to provide increased commercial air service through staggered
bookings. As you may know, many auto arrivals are now made
necessary due to peaking on our airlines on Saturdays. If we
could distribute vacation packages to anything other than straight
Saturday to Saturday, then additional air trips and fewer auto
trips to Aspen will be available. In addition to specific program
' changes, we will encourage and perhaps help finance additional
advanced marketing information to prospective tourists to advise
them of how to best avoid the bad drive from Denver to Aspen. In
further support of this idea the County -,us system has been greatly
~-' expanded as has Aspen Ski Corp. Service. The D.E.I.S. should con-
sider the impact on mode of arrival and does not.
$. More information should be provided on the duration of peak traffic
volumes. This would enable the public to choose between the various
' alternatives. For example, if a two lane improved alternative would
offer a service level "E" for 1990 average peak hour volume it would
be useful to know how many days a year this might occur and for
how long each day. Certainly some trade off economics must exist
between alternatives which range from 13 to 65 pillion. It may
be worthwhile to sustain service level "E" for several hours a
' -day for 100 days of the year if this could spell millions of
-dollars in savings. The D.E.I.S. should deal more with alternatives
which reflect costs effectiveness.
9. The D.E.I.S. could benefit by several technical additions and/or
corrections as follows:
,,r' .
cvovemoer ~, lyid
Page Five
a. Table 25 (p.101) could be updated to include 75-76 data.
• SKIER VIS1T5 75-76
Aspen Highlands - 320, 790; Aspen Mountain - 240, 800;
$uttermilk - 214, 500; Snowmass - 636, 800;
Total 4-area - 1,413,890; annual percent increase 4.2%
Source: Aspen Skiing Corp. Phone conversation with
Peter Sullivan.
b. Tables 1 and 2 on pg. 89 should reflect most recent
' population analysis to read:
Pitkin County 1975 estimated population = 13,252 and
City of Aspen 1975 estimated population -~ 5,889. Both
of these figures represent estimates of total permanent
population. Tourist capacity exists to house an additional
.18,529 tourists. Source: Aspen/Pitkin Planning Department.
~_Social Comments ,~~
1. The sociological assessment listed many facts and very little
analysis is generated. The only conclusion stated was that "a
majority of the families residing within the corridor are living
in mobile homes."
Page I08 of the D.E.I.S. makes two statements which likely could
have major sociological impacts to the valley. The first is that
the four lane alternatives are five times as labor intensive as
the two lane alternatives ($20,000,000 vs. $4,000,000 labor cost).
The second statement is that "a small percentage of the jobs may
be filled by residents in the project area."
The questions of providing employee housing, increased governmental
service requirements and the long term area-wide effects of the
`~svarying population impacts created by the two and four lane
alternatives was not addressed. The possible problem of the boom
town condition should be examined.
2. Financial Impact Assessment of Local Governments was not examined.
Prior discussion mentiona the amenities (parking structures, etc.)
• that would be required as a result of the implementation of any
Carbondale East project. Also, the social costs associated with
respect to accommodating the construction of any such project
further add to the local governments: responsibilities. A full and
-Complete analysis of all financial liabilities placed upon all
local governments of the valley should be de~~eloped with respect
to each highway alternative.
3. The impact of the lifestyle attraction of the City of Aspen was
not examined. Many current Aspen citizens have cYiosen that City
for their place of residence due to its lack of urbanization and
the effects of urban type improvements. A four lane highway entering
Page Six
Aspen is likely to create a "consicousness alteration" of the
community, the result of which could be the eventual changing
of the character and ~:ake up of its citizenry. This possible
sociological phenomenon was not identified and it should be
examined. `
Economic Comments
1. A statement made on p. 111 of the D.E.I.S. reads as follows:
"The improved facility coupled with an improved facility through
Glenwood Canyon could ma'.~e the Aspen resort more accessable to
population in the Denver :Metro area during the winter months.
The ski areas in Aspen could increasingly be viewed as a weekend
trip."
It is noted one of the principal objections noted in visitor
surveys is that the in-town auto congestion and hassle was de-
grading the resort and, they might not return as a result. The
probable adverse economic impact of substantial additional
commuting and resultant traffic congestion in the resort should
be analyzed.
~, .
This statement implies that the Aspen area would welccme an in-
flux of weekend skiers along with their vehicles. This is contrary
to the current marketing policy of the Aspen/Snowmass ski in-
dustry - as this area is a winter destination resort accommodating
tourists on a week to week basis. Very little, if any, lodging
capacity is available on a weekend basis. Under current conditions,
weekend visitors could not be accommodated and it is likely that
a four lane g hway would work contrary to the destination resort
policy. \ -
If summer tourism continues to increase at present rates, it is
~~uite possible for the upper Roaring Fork Valley to develop the
destination resort concept for the summer visitor. It has been
speculated that the closing of Independence Pass to highway traffic
would greatly further this concept, and this issue was not
identified or analyzed in the D.E.I.S. Closing of Independence
Pass could lead to reduced traffic loading on the Carbondale East
section of S.H. 82, reducing the apparent necessity for a four
lane facility. A further study of the summer destination resort/
-Independez~:e Pass question should be made. •
2. Page 175 of the D.E.I.S. states that. the upgrading of S.H. 82
will provide for "considerable savings in highway user costs over
the 20 year design life of the highway." The expense incurred to
Eain this apparent savings with respect to the two and four Iane
highway alternatives were not developed. The total energy re-
wuired to construct a~nJ the total taxpayer dollars required to
finance each highway alternative should he compared relative to t're
estimated return to users in the form of fuel and vehicle maintenance
-November 9, 1976
Page Seven
savings. This statement applies to the remarks on fuel savings
within the last paragraph.~f p.175. -
3. Nowhere in the D.E.Z.S. is there analysis and discussion on the
cost of maintaining each of the alternatives under consideration. _
It is most certain that annual maintenance and replacement costs
will vary significantly between the two and four lane alternatives
and it is likely that the State would be responsible for those
costs. Analysis of these°costs should be included in the final E.I.S.
4. Page 178 of the D.E.Z.S. states that increased patrol throughout
the corridor is "unrealistic because of its fiscal budget and -
~manpower limitations." The most costly four lane alternative being
considered is estimated to bear a $65 million price tag. The
annual costs of additional patroling of the Carbondale East section
of S.H. 82 over an infinite period of time would be insignificant °
relative to four lane construction costs. The above mentioned
statement should be reconsidered.
5. The impact of commercial development at each key intersection
should be discussed and evaluated.
~~
Environmental Comments
1. The last paragraph on p.149 states that the improvement of S.A.
82 "will slightly reduce the pollutants emitted by vehicular
traffic. This will be accomplis'tied by providing a more efficient
-transportation facility which will eliminate congestion, inter-
rupted traffic flows, and ." This is contradictory to a state-
ment on p.112 "secondary growth will create some additional in
town parking and congestion problems in Aspen." Also the increase
in traffic to Aspen as a result of increased commuting from
down valley should be analysed. - .
The townsite of Aspen is where most human activity occurs, and
--due to increased traffic and congestion in Aspen created by an
improved highway, a reduction in air quality will automatically
occur. Any improvement in air quality along the travel corridor
of Carbondale East is irrevelant as it is a slight improving of a
bad situation, whereas, a reduction of the air quality within the
City of Aspen affects all humans living within the D.E.I.S. and
should be included in the final E.I.S. ~`
~~ ° E~
2. Page 183 of the D.E.I.S. - Gravel Excavation discussion is not /J1~'~
comprehensive enough. The analysis mentions that "the total pro- i f~;L`,
feet will require a lar.~e amount of gravel." No indication was ~i),w;,.
given as to what quantities of gravel material would be required ~/
for each alternative, where the material might be mined and what
the altered land forms would look like upon completion of the pro-
~ect~and taking of the material. This relates to the physical and
Richard Procense --
November 9, 1976
Page Eight
._ _ __ esthetic damage statement on the same page of the D.E.I.S.
The esthetics statement is highly subjective and made without
close an~ysis of the gravel source question.
The last section of S.H. 82 four laned (Carbondale area) in 1974
and 1975 has remaining inoperative gravel pits which are currently
-- abondoned without any apparent revegetating or stabilizing of
steep cut slopes. If these unsightly cut slopes are considered as
an automatic result of a four lane highway project, this should be
indicated within this D.E.I.S. Analysis and discussion on gravel
- - - material sources, locations and management of revegetating these
potential sources should be done in a more thorough fashion in the
- final E.I.S.
- .° In light of the above mentioned considerations and examination of the ~°
D.E.I.S., it would be prudent to develop an improved two lane highway
- ~ -with immediate safety improvements. This would allow the State to
• - - escrow the dollar savings realized by not building a four lane and
- ~ use these monies in the future for a four lane should it be ultimately
•decided to be the only solution, or perhaps alternative transporatian
___ 'systems. Such a decision would provide immediate relief to an unsafe
• Yoad, allow great dollar savings, and provide the ability to expand the
highway in increments should it be desired.
-- For these reasons at this time we support the construction of Alternative
'- 1D, 3D and defer comment on the Airport to Aspen section until the
• completion of our transportation alternatives analysis which will carry
- 'with it direct recommendations for the design of this critical section
of road. °-
- --- Our comments will also be made available at the Public Hearing on
- November 22, 1976.
_...
~~ ~ -_ -Thank you for the report and the opportunity to respond on behalf of
our constituents.
- Sincerely,
-.
- _J eph E wards, Jr. _ _ _
Ch ~''~
PIT IN .COUNTY BOARD.-OF COMMISSIONERS ~ -
Stacy Standley, Mayor _
CITY OF ASPEPI, COLORADO - /
JEE-SS/
rxu~w~~L r~UK llEVELOP'~SI,NT OI A JOINT
TRANSPOI;TI~TION PROGRAM
Introduction
Review of the Carbondale East D.E.I.S, brought forth a consideration
about the length of the entire review and financial planning process
involved initiating any highway project. The time involved in
preparation for a project of the scale of Carbondale East is very
lengthy, and while this process is occuring the citizenry and guests
of the Roaring Fork Valley continue suffering under the current
conditions of State Highway 82. It is likely that at least another
three to five years will pass prior to the commencement of any
Carbondale East project as outlined in the D.E.I.S.
Following is a four point program offered to the State Highway
Department which, if supported and carried forth, might do a lot
to minimize the impact of the existing traffic conditions of State
Highway 82. Also, this proposed program may give local governments
and the State Highway Department an opportunity to work together
in a program which could prove valuable, experience wise, to both
entities.
1. Upgrading of Existing Two Lane Highway
A strict highway access program should be instituted and enforced.
-This would include negotiating with the property owners of some of
the current access points to develop joint access points where
ever possible. Continuance of this year's joint turnoff lane
development program with Pitkin County,.and development of left
hand turning lanes at key intersections. A resurfacing of the
entire highway from the West City limits of. Aspen to the Ranch at
Roaring Fork should be accomplished as soon as possible. THe
Maroon Creek Bridge should be examined and then provided with
additional supports or replaced to relieve the swaying which re-
' sults in the continual asphalt breakup at the joints. An
immediate reduction of the 40 mph speed limit through Basalt to
.' 30 mph could be accomplished, providing additional safeguards for
the users of the new business district and high school adjacent to
the highway. 'Ilse shoulder widening program which~.began on the
-"• west side of-Aspen should be continued all the way to the
~Gerbazdale area. These shoulders should be gr4ded and snowplowed
for year around use for emergency purposes. Also, more guard
railing could be installed along the more critical sections
throughout the entire Carbondale East section of S.Ii. 82.
2. Cooperation with Local Government Transportation Programs
Currently Pitkin County has a bus system serving the residents
of Garfield, Eagle and Pitkin Counties. Joint participation in
the lease or purchase of }cey properties adjacent to major
intersections, e.g. Emma Road, Brush Creek Road, for use as park
i
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and ride facilities. Attractive park like parking lots with
bicycle racks and other amenities could be developed at these
sites encouraging the citizenry to use public transportation.
Pitkin County is currently involved in a piggyback UP~ITA grant
to purchase three necv buses for use on its Aspen Valley runs.
Letters of support and lobbying on the part of State Highway
Officials could greatly enhance she County's chances of gaining
such grants. Also, the Highway Department could provide
encouragement to the other local governments in the valley to
submit grant apclications for equipment to provide greater
public transportation services, e.g. Colorado !Mountain College,
the City of Glen~•~ood Springs, Garfield County, etc. Enclosed is
a rough sketch of a park and ride facility at Emma Road Inter-
section (Basalt). -
Support for other current County grants could be given by the
State Highway Department. The transportation alternatives study
grant sponsored by U~4TA and the bicycle oath grant request to
the Highway Department could, if carried out and accomplished, create
traffic diversions from S.~i. 82, and with State Highway Department
involvement and participation, might be accomplished sooner.
A '~
3. On-Going Techhical Services Program with Local Governments.
An in depth traffic survey and counting program could be developed
under the State Highway Department with all local governments
participating. Monthly surveys could be made using local govern-
ment personnel, determining who uses the highway and for what
purposes. From this type of data, or more accurate estimations of
possible auto trip diversions could be made. These figures could
-assist local governments in developing year around public transit
•routes and schedules to best meet the needs of the citizenry and
to reduce the auto impact on S.H. 82. Other technical support
could be in the form of thorough accident analysis to determine
where the accidents occur on the highway and the cases. These
analysises could be so detailed as to call for traffic engineers
to interview victims, patrolmen traffic conditions at the time
of the incident, etc. This type of thorough investigation might
rapidly identify a need for immediate improvements at specific
:sections of the hiahcaay which could be developed prior to those
sections of the highway where accidents occur least.
.Should any Carbondale East program be approved by the State Highway
Commission, it is likely that it would take a number of years to
- develop and the most dangerous sections might be accomplished
earlier than the less traveled, less dangerous sections of the
highway.
4. Improved Maintenance and PatrolinQ of S.H. 82.
Several specific items which could be improved upon or instituted
to make the highway safer immediately are:
a. Lobby the State Patrol for an additional patrolman on duty
between Carbondale and aspen who could provide additional
assistance for speeding reduction. •
i a.
b. Provide a local listed phone number for Aspen, Basalt, and
Carbondale citizens to call when unexpected *aeather
conditions create unsafe conditions along the highway.
Currently, the only place to call is Glenwood S~rinys.
A 963, 927 and 923, 925 listing could be provided For,
listed as STATE OF COLOIZr'1DU, fIighway Maintenance. In
addition, road construction information could be provided
through local radio stations.
c. Joint participation with Pitkin County for an improved
facility for road maintenance. The State's facility west
of Aspen is minimal and the County is considering the
• development of a new facility witriin the next several years.
- By sharing one facility, both agencies might be able to pro-
vide better service at a savings to the public.
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